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Open warfare?

19 July 2016 / Philip Fisher , Dawn Register
Issue: 4559 / Categories: Comment & Analysis

The collateral damage resulting from a worrying new HMRC campaign.


  • HMRC is using two separate pieces of legislation in a worrying but effective new strategy.
  • ITEPA 2003 s 689 allows PAYE recovery from companies that employ individuals indirectly.
  • PAYE Regulations reg 80 allows tax to be recovered from an employer if another party has failed to pay.
  • Problems can arise when one party is unaware of others in the supply chain and cannot verify amounts.
  • It seems likely that National Insurance contributions will be recovered using similar powers.
  • Scheme promoters may be at risk.

Like the Grand Old Duke of York HMRC does love its campaigns. Although they may not be military ones the consequences can be as devastating for those on the receiving end....

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